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IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: MERVYNS HOLDINGS, LLC, et al., Debtors.

) ) ) ) ) ) Chapter 11 Case No. 08-11586 (KG) Jointly Administered

RESPONSE OF HAMILTON FIXTURES, INC. TO DEBTORS ELEVENTH OMNIBUS OBJECTION (SUBSTANTIVE) TO CERTAIN OVERSTATED CLAIMS AND MOTION TO REDUCE OR EXPUNGE CLAIMS Now comes Hamilton Fixtures, Inc. (Claimant) and in response to the Debtors

Eleventh Omnibus Objection (Substantive) to Certain Overstated Claims and Motion to Reduce or Expunge Claims (the Objection), by and through counsel and states as follows: 1. The Objection asserts that a portion of Proof of Claim (No. 5344) filed by

Claimant (the Claim) as a General Unsecured claim is overstated, based upon the books and records of the Debtors. By the Objection, the Debtors seek to have the general unsecured portion of the Claim disallowed and expunged. 2. Attached to the Claim is a detailed explanation of the basis for the unsecured

portion of the Claim and, includes a list of the inventory which is the subject of the Claim. The Debtors objection misses the point. The claim is filed as notice of a damage claim, not as a claim for goods shipped and received by the Debtors. The fact that the Claim is not on the books and records of the Debtors is not relevant to the basis of the Claim. Over time, and in response to the identified and anticipated needs of the Debtors, Claimant has purchased and assembled inventory which is unique to the fixtures furnished to the Debtors by the Claimant, so that the fixtures to be sold to the Debtors would be delivered on a timely basis. To the extent Claimant is

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unable to sell the inventory to the Debtors, the Claimant has been damaged by the Debtors failure to purchase the fixtures as identified and anticipated by the parties. 3. In support of this response, Claimant asserts as follows: (a) Claimant s Name: Hamilton Fixtures, 3550 Symmes Rd., Hamilton, OH 45015. (b) Documentation and Explanation of Amount of Claim: Attached to the Claim is a detailed explanation. (c) Party with personal knowledge of relevant facts: Janet Schlegel, CFO, Hamilton Fixtures, Inc., 3550 Symmes Rd., Hamilton, OH 45015, (513) 870-1490. (d) Other documentation: Counsel for Claimant is reviewing additional

information and documentation, which will be furnished to counsel for the Debtors prior to the scheduled hearing. (e) Address for service of reply to this response: Jack R. Pigman, Porter, Wright, Morris & Arthur LLP, 41 South High Street, Columbus, Ohio 43215, (614) 227-2119 / Facsimile (614) 227-2100 (f) (g) Additional addresses: Same as (e), above. Additional information: A portion of claim No. 5344 was filed as a Priority Claim pursuant to Section 503(b)(9) of the Bankruptcy Code to the extent that a portion of the inventory delivered by Claimant to the Debtors within twenty days prior to the filing of the bankruptcy case. Apparently there is no disagreement between the parties with respect to that portion of the Claim.

Wherefore, Claimant respectfully requests that the Court enter an order denying the Objection as it relates to the general unsecured portion of the Claim of Claimant.

November 10, 2009

/s/ Jack R. Pigman Jack R. Pigman (OH 0023023) Porter, Wright, Morris & Arthur LLP 41 South High Street Columbus, Ohio 43215 (614) 227-2119 / Facsimile (614) 227-2100 jpigman@porterwright.com Co-counsel to Hamilton Fixtures, Inc. CERTIFICATE OF SERVICE

The undersigned hereby certify that a true and exact copy of the foregoing has been served this 10th day of November, 2009 via CM/ECF System and by regular U.S. mail, postage prepaid upon: Mark D. Collins (No. 2981) Daniel J. DeFranceschi (No. 2732) Christopher M. Samis (No. 4909) Katisha D. Fortune (No. 4857) RICHARDS, LAYTON & FINGER, P.A. One Rodney Square 920 North King Street Wilmington, Delaware 19801 Howard S. Beltzer Wendy S. Walker MORGAN, LEWIS & BOCKIUS LLP 101 Park Avenue New York, New York 10178-0060 /s/ Jack R. Pigman Jack R. Pigman (OH 0023023) Porter, Wright, Morris & Arthur LLP 41 South High Street Columbus, Ohio 43215 (614) 227-2119 / Facsimile (614) 227-2100 jpigman@porterwright.com Co-counsel to Hamilton Fixtures, Inc.

COLUMBUS/1513619 v.01

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